Search the Pension Law Library

61. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    at 568 – 69. Petitioner has not explained why the result should be different here. Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . . made by reason …
62. PLR 202020006 — Governmental Plan
    IRCPrivate Letter RulingsMay 15, 2020
    …excepted from the term “employment.” FICA taxes include social security and Medicare taxes. Section 3121(v)(1)(B) provides that, other than the social security tax wage base limitation, nothing in § 3121(a) excludes from the term “wages” any amount picked up as an employer contribution under § 414(h)(2) if the pick-up …
63. 88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02
    ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
    y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
64. 88 FR 74386 — Disclosure of Records
    IRCProposed Rules (FR)Proposed Oct 31, 2023related by meaning
    to a state, and (3) must not be released by a state to the public or any third party, unless explicitly approved in writing, in advance, by Treasury. (d) Liability. Treasury is not liable for any loss, liability, cost, or expense that may result from a state's receipt, use, or distribution of records or any information…
65. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    IRCCourt RulingsMay 28, 2003related by meaning
    r the Northern District of Illinois, in which petitioner pleaded guilty to one count of obstructing and impeding the due administration of the Code in violation of section 7212(a). 3 - 6 - 3 (...continued) corruptly or by force or threats of force (including any threatening letter or communication) endeavors to intimid…
66. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    …s pay is a neutral factor for purposes of determining petitioner's employment status. Under section 3121(b) (11), "service performed in the employ-of a foreign government" is excepted from "employment" for purposes of Social Security and Medicare taxes. See sec. 31.3121(b) (11) 1, Employment Tax Regs. Services excepted…
67. 29 C.F.R. § 2520.104-28 — [Reserved]
    ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
68. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987
    …e unemployment tax provisions. “Employment” was defined as service performed by an “employee.” Sec. 3121(b). Excepted from the definition of employment was “service performed in the employ of the United States * * * if such service is covered by a retirement system established by a law of the United States.” Sec. 3121(…
69. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
70. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014related by meaning
    on 6301 empowers the Commissioner to collect the taxes imposed by the internal revenue laws. To further that objective, Congress has provided that the Commissioner may effect the collection of taxes by, among other methods, liens and levies. Section 6321 imposes a lien in favor of the United States on all property and …